In Illinois Farmers Insurance Co. v. Glass Service Co., 8 the Minnesota Supreme Court had the opportunity to revisit its 1973 decision in Grover-Dimond Associates v. American Arbitration Ass'n 9 in light of conflicting case law developed since that time.' 0 This Note will address the current split in state and federal courts, and suggest that the best way to resolve this issue is through state adoption of the RUAA.
Jonathan R. Waldron,
Resolving a Split: May Courts Order Consolidation of Arbitration Proceedings Absent Express Agreement by the Parties,
2005 J. Disp. Resol.
Available at: https://scholarship.law.missouri.edu/jdr/vol2005/iss1/12